01 Final Rule: Succession Planning Is Now in Effect
The most immediate action item for credit unions is the final rule on succession planning, which took effect on January 1, 2026. All federally insured credit unions are now required to maintain a formal, board-approved written succession plan for key positions.
What the Rule Requires
Board Approval: The board of directors must approve and maintain a written succession plan that reflects the credit union’s size and complexity.
Periodic Review: The board must review the plan at least once every 24 months to ensure it remains current and relevant.
New Director Onboarding: Newly appointed board members must become familiar with the succession plan within six months of their appointment.
Credit unions that have not yet formalized their succession planning process should treat this as a near-term priority. Examiners will be looking for documented evidence of board-level engagement with the plan, not simply a filed document.
02 The Deregulation Project: Proposed Rule Changes
Responding to a 2025 executive order directing federal agencies to reduce regulatory burden, the NCUA has launched a comprehensive review of its rulebook. The agency’s “Deregulation Project” has already generated several rounds of proposed changes, with initial comment periods closing in February and March 2026.
The following proposals are currently in the public comment or agency review stage:
Corporate Credit Unions
ALCO Composition & Reporting Relief
Proposed amendments would remove the requirement for a board member to sit on the asset and liability management committee (ALCO) and would eliminate certain mandatory annual reporting requirements, reducing administrative overhead for corporate credit unions.
Audit
Supervisory Committee Audit Flexibility
The NCUA is proposing changes to streamline supervisory committee audit regulations, granting credit unions greater operational flexibility in how they structure and conduct these audits.
⚠ Comment Period Closes June 6, 2026
Chartering & Field of Membership — Associational Common Bond
This proposal would amend the associational common bond rules to remove the automatic disqualification for associations that require members to purchase a product or service as a condition of membership. Instead, the NCUA would conduct a more holistic evaluation on a case-by-case basis.
Data Security
Safeguarding Member Information — Part 748 Guidance Shift
The agency intends to remove Appendix A of Part 748, which currently houses guidelines for safeguarding member information. The guidance would be reissued as a Letter to Credit Unions, making it easier for the NCUA to update the requirements without triggering a full rulemaking process.
Lending
Loans to Other Credit Unions — Board Approval Removed
Under this proposal, credit unions would no longer be required to obtain board approval before making loans to other credit unions, nor would they need to maintain formal written internal limits for such loans — streamlining what has historically been a low-risk transaction type.
03 2026 Supervisory Priorities & Examination Updates
The NCUA’s supervisory priorities for 2026 set the examination agenda for the year. Credit unions should expect examiners to concentrate on the following areas:
| Priority | Detail |
|---|---|
| BSA / AML | Examiners will scrutinize Bank Secrecy Act and Anti-Money Laundering programs with particular attention to whether controls are calibrated to each institution’s specific risk profile — not simply whether a program exists on paper. |
| Fraud | The agency continues to flag fraud risk as a top concern, with examiners evaluating the adequacy of internal controls, segregation of duties, and detection mechanisms. |
| Exam Cycles | The NCUA is extending the examination cycle to up to 24 months for well-managed credit unions, reducing the examination burden for higher-performing institutions. |
| Reputation Risk | The NCUA is discontinuing the use of “reputation risk” as a supervisory concept — removing a subjective and often contested element from the examination process. |
| Stablecoins | The NCUA will continue its work to implement the Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act, signaling that digital asset readiness remains a forward-looking supervisory concern. |
Bottom Line for Credit Union Leaders
The current NCUA landscape reflects a rare moment of simultaneous tightening and loosening. The succession planning rule is not proposed — it is in effect now, and boards should verify compliance immediately if they haven’t already.
On the deregulation side, credit unions with strong advocacy resources should take advantage of open comment periods (particularly the Field of Membership proposal closing June 6) to shape rules that affect their membership structure.
For examination preparation, the shift toward risk-profiled BSA/AML scrutiny means generic compliance programs will face greater scrutiny than ever. Institutions that can demonstrate their controls are thoughtfully tailored to their actual risk environment will be well positioned heading into exam season.